Having spent much of the past year writing about working conditions at Apple’s supplier factories in China, I couldn’t help but read Richard Locke’s informative essay with Apple in mind.

Using Nike as his primary case study, Locke concludes that the efforts of private companies to improve labor standards have had little effect. This failure can be partly explained by the mixed motivations of private companies, as their interests in improving labor standards are often in conflict with their interests in extraordinarily tight production schedules and low costs. Parallels with Apple abound.

As with Nike, Apple’s intensified commitment to improving labor standards has largely been driven by the desire to avoid further bad publicity—in Apple’s case, a series of high-profile stories in the New York Times and other publications describing the brutal living and working conditions faced by the people making its popular and lucrative (for Apple) products. As with Nike, Apple’s primary response has been private regulation: the company is pushing for reform itself, through a code of conduct, audits, and direct pressure on its suppliers.

The Nike results, according to Locke: “while some factories appear to have been substantially or fully compliant with Nike’s code of conduct, others have suffered from persistent problems with wages, work hours, and employee health and safety.” The Apple results to date, according to a recent analysis of Apple’s latest supplier-responsibility report, which I coauthored with Scott Nova of the Worker Rights Consortium: “Apple’s own data from this and previous reports demonstrate that the rights of workers continue to be violated on a routine basis in Apple’s supply chain, and it is not clear that the modest progress reported shows Apple to be on a path to deeper reform.”

Locke’s article points to the underlying cause of private regulation’s failure: the conflicting interests of the companies themselves. Locke’s general concern applies to Apple. At the same time Apple has publicly emphasized its seriousness about improving labor standards, it has continued to use supply chain practices, such as excessively burdensome production schedules, that undermine such standards. And in this regard, Apple is not forthcoming. Its recent supplier-responsibility report is silent on potential changes to its own purchasing practices.

Apple’s recent supplier-responsibility report is silent on changes to its purchasing practices.

Most of Apple’s major reforms are scheduled to begin in July, so we cannot yet be sure what progress the company will make. Will Apple deliver the decent working conditions that Nike has failed to produce? Locke ends his essay by recommending government action as a means of reform. But while governmental support of labor standards would be welcome, with most of Apple’s production occurring in China, that option does not provide much hope in this instance, particularly in the near term.

Instead, beyond Apple reforming its own supply chain practices or buying from factories in countries that uphold labor standards, the most fruitful path is one given only modest consideration by Locke. That is, to establish a role for workers and NGOs whose interests in improving labor standards are not as complex as those of a buyer or supplier, nor as tenuous as those of even a progressive government.

In China in particular, where freedom of expression is limited and real unions do not exist, empowering independent, strong voices is a gigantic challenge. But Apple and others could take significant steps in this direction.

Brands could insist that their suppliers establish genuine bargaining rights for their workers and allow truly democratic elections of worker representatives at the factory level. Brands could participate directly in the bargaining process, ensuring that workers’ perspectives are included.

Apple and other companies could also commit to reforms by codifying them in an enforceable, binding agreement with international worker representatives.

And brands could engage with and pay heed to NGOs such as China Labor Watch and Hong Kong–based Students and Scholars Against Corporate Misbehavior. These NGOs are fully independent and for years have reported on working conditions at Chinese suppliers while also recommending reforms.

Locke’s review of the past two decades of efforts to advance labor standards is illuminating, but his conclusion that renewed governmental effort offers the best path to reform is incomplete. Progress will require activity across the board. Serious private regulation and governmental reforms, where feasible, are necessary, but unless global brands such as Apple seriously engage with independent voices representing the interests of workers, progress on labor standards will likely remain meager.